Crying Wolf: Is the public really at risk and do we really need another licensing exam?

The Association of State and Provincial Psychology Boards (ASPPB) has repeatedly explained that its mission is to support licensing boards in meeting their goal of public protection. With this in mind, on March 21, 2016, the ASPPB announced its intention to create a competency exam, the Examination for Professional Practice of Psychology Step 2 (EPPP2), which the ASPPB expects to be ready for implementation by January of 2019. Unlike the EPPP, which is intended to assess knowledge, the EPPP2 is intended to assess competency-based skills. While public protection is an admirable goal, and one which I believe the ASPPB is sincerely committed to, it’s unclear how this additional test would help licensing boards meet their goal of public protection. The EPPP itself has been subject to many critiques that remain unanswered, critiques that would likely apply to the EPPP2 as well. Due to the significant investments of time and money students will be required to make in taking the EPPP2 (the cost of the EPPP is $687 in most jurisdictions, and half of test takers spend over 200 hours preparing), these critiques should be addressed prior to the implementation of the EPPP2.

First, it remains unclear whether the EPPP itself has resulted in improved professional performance or advanced the goal of public protection. As Sharpless and Barber (2009) note:

“Although the EPPP is used nationwide for U.S. licensure applicants, we are not aware of any published studies showing that EPPP performance (a) is associated with relevant professional performance criteria, (b) is predictive of future professional performance, (c) incrementally adds to the ability of boards to license appropriate candidates, or (d) protects the public. Given the fact that the EPPP is a high-stakes examination that requires a significant investment of time and money from applicants…we believe that this lack of validity testing warrants further attention, as we are currently unaware of evidence that EPPP performance is associated with being a better psychologist (emphasis added).”

In his response to Sharpless and Barber, Stephen DeMers, Executive Officer of the ASPPB, explains:

 “[T]he EPPP is not intended to be a comprehensive assessment of professional competence. Rather, it is intended to be an assessment of the knowledge base deemed essential for competent practice, which is quite different from directly assessing competence…But it is unfair to criticize the EPPP as not adequately assessing competence to practice when it was never intended nor claimed to do this (DeMers, 2009).”

DeMers distinguishes between assessment of the knowledge base needed for competent practice versus the assessment of competence. However, it remains unclear whether EPPP is accurately assessing the knowledge base essential for competent practice.

One way of testing whether the EPPP is indeed assessing knowledge essential for competent practice, as Sharpless and Barber suggest (2013), is to to ask experienced and licensed psychologists to take the EPPP without benefit of the 200 hours of preparation typically required for novices to pass.

“If the EPPP indeed measures knowledge essential for the practice of professional psychology, they should have few difficulties passing the exam. We surmise however, that a number of well-respected and competent practitioners would indeed fail…if the EPPP information is not retained, or necessary to retain for competent and effective practice, it may not be meeting its developers stated goals.”

There continues to be a dearth of evidence demonstrating that the EPPP accurately assesses the knowledge necessary for competent practice. Before the EPPP2 is implemented, the ASPPB should provide this evidence for the EPPP—otherwise, we risk “putting the cart before the horse.”

Second, White students have been found to pass the EPPP at over twice the rate of African American and other minority groups (Werner, 1981).  Sharpless and Barber (2013), found that individuals from programs with high numbers of ethnic minority students have more difficulty passing than those from programs that are more homogenously White. The findings are especially important considering the efforts to recruit ethnic minorities into the profession due to the lack of diversity among psychologists when compared with the general workforce (84% of psychologists are White versus 61% of the general population). Before it launches a competency exam, the ASPPB should investigate whether the EPPP is biased toward certain groups and release its findings publicly. By not doing so, the ASPPB risks perpetuating the same bias in the EPPP2.

Third, ethics violations, which presumably would indicate whether psychologists are competent or not, are extremely rare. In Louisiana, for example, from 2010 to 2014 there were 1.6 disciplinary actions taken for approximately 700 psychologists, or a rate of .002 percent. Nationally, in 2014 the rate was 1 in 634, or .0016 percent. While ethics complaints and disciplinary actions are not the only way to measure competence, they would appear to be an important indicator of the need for additional measures aimed at protecting the public. Considering the extremely low rate of disciplinary actions against psychologists, it is unclear why a competency exam is currently necessary.

Finally, economists have noted a historical trend where the barriers to entry increase, and salaries decrease, as women and minorities enter a field in increasing numbers (Altonji & Blank, 1999). The addition of the EPPP2 as a requirement for psychology practice is consistent with this trend. Clinical psychology students today engage in far more hours of pre-doctoral training than in previous years. These hours have increased so dramatically that the APA has called for the elimination of post-doctoral training requirements. Moreover, Olvey, Hogg, and Counts (2002) note that the number of years required for a doctoral degree in psychology has grown from 4 years to an average of almost 7 years. Psychologists have the longest time to licensure, and top-of-the line requirements, when compared with other health professionals, yet are among the lowest paid. The EPPP2 would only add one more burden to carry for the already over-trained, and soon-to-be underpaid, psychologist in training.

There is a question of fairness here—why should women and minorities be held to a higher standard than the mostly White males who previously numerically dominated the field? The only justifiable reason for increasing requirements for entry into the profession is that these additions result in psychologists who are better prepared to exercise their profession and less likely to harm the public. However, as demonstrated above, there is no evidence that the increased licensing requirements have resulted in better psychologists.

In sum, the stated purpose of the ASPPB is to support licensing boards in meeting their goal of public protection. However, it is unclear that the EPPP2 would advance this goal as critiques of the EPPP likely apply to the EPPP2. First, there is no evidence that the EPPP is assessing the knowledge base essential for competent practice. Second, EPPP may be biased against Black and other students of color. Third, ethics violations are extremely low and do not indicate a need for additional measures to protect the public. And finally, the ASPPB must consider the history of increasing requirements as women and minorities enter a field, as well as the current licensing requirements in comparison with other professions, in deciding whether another test is warranted. The profession is likely already missing out on many of the “best and the brightest” due to the licensing requirements versus pay disparity. Without taking the whole picture into account, the ASPPB risks doing more harm than good to the profession.

Note:  A version of tis article was originally published in the The National Psychologist, January/February 2017 Issue.

Editor’s Note: For more information, check out APAGS’ initial thoughts on the EPPP2 and the ASPPB response to that post.


Altonji, J. G., & Blank, R. M. (1999). Race and gender in the labor market. Handbook of labor economics, 3, 3143-3259.

DeMers, S. T. (2009). Understanding the purpose, strengths, and limitations of the EPPP: A response to Sharpless and Barber. Professional Psychology: Research and Practice, 40(4), 348.

De Vaney Olvey, C., Hogg, A., & Counts, W. (2002). Licensure requirements: Have we raised the bar too far? Professional Psychology: Research and Practice, 33(3), 323.

Sharpless, B. A., & Barber, J. P. (2009). The Examination for Professional Practice in Psychology (EPPP) in the era of evidence-based practice. Professional Psychology: Research and Practice, 40(4), 333.

Sharpless, B. A., & Barber, J. P. (2013). Predictors of program performance on the Examination for Professional Practice in Psychology (EPPP). Professional Psychology: Research and Practice, 44(4), 208.

Werner, E. (1981). A review of the Examination for Professional Practice in Psychology. Sacramento, CA: California Department of Consumer Affairs.

4 thoughts on “Crying Wolf: Is the public really at risk and do we really need another licensing exam?

  1. David Meyerson

    Fantastic post, Luciano. What are your thoughts on replacing the EPPP with the EPPP2? I would predict that most practicing psychologists found the EPPP to be a waste of time and money, as it does not appropriate assess whether one would make a good clinician. Perhaps a competency-based assessment – akin to the residency and fellowship Board exams for MDs and DOs – would be more appropriate?

    1. Luciano Lima

      Hi David. I think replacing the EPPP with the EPPP2 would be better than keeping both, but I would still need the questions I raise in the article to be addressed. I’m not sure whether the Boards for MD’s are less biased against certain groups or whether they are demonstrably doing a better job of “protecting the public” but if they are, we could look to them as a model we could learn from.

  2. Pingback: Modern Psychologist ASPPB Psychologists Doing More Harm Than Good to the Public - Modern Psychologist

  3. Andrea Bradford, Ph.D.

    You wrote, “Considering the extremely low rate of disciplinary actions against psychologists, it is unclear why a competency exam is currently necessary.”

    Don’t be so quick to assume that the rate of disciplinary action reflects the actual rate of malpractice in the profession. There are many reasons why board complaints are never investigated or never lead to formal disciplinary action. There are even more reasons why people never complain to the board in the first place, including fear of retaliation, concerns about exposure of their sensitive information, and feelings of hopelessness or disenfranchisement.

    As professionals, our first duty is to our clients and patients. Therefore, I welcome a competency-based evaluation process more akin to those of our colleagues in other health professions. Meanwhile, we must demand that universities and K-12 districts eliminate educational disparities earlier in the pipeline, and we must advocate for the elimination of predatory programs that consistently exploit underprepared trainees and maintain little accountability for student outcomes.

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